Dairy 101

Dairy 101

About Food & Water Watch Food & Water Watch is a nonprofit consumer organization that works to ensure clean water and safe food. We challenge the corporate control and abuse of our food and water resources by empowering people to take action and by transforming the public consciousness about what we eat and drink. Food & Water Watch works with grassroots organizations around the world to create an economically and environmentally viable future. Through research, public and policymaker education, media and lobbying, we advocate policies that guarantee safe, wholesome food produced in a humane and sustainable manner, and public, rather than private, control of water resources including oceans, rivers and groundwater. Food & Water Watch 1616 P St. NW, Suite 300 Washington, DC 20036 tel: (202) 683-2500 fax: (202) 683-2501 [email protected] www.foodandwaterwatch.org Copyright © October 2008 by Food & Water Watch. All rights reserved. This report can be viewed or downloaded at www.foodandwaterwatch.org.

Dairy 101 Introduction............................................................................................................................................................1 Industrial Milk Production: A Beast of a System.......................................................................................................................1 Free Market or a Free Ride?.........................................................................................................................................................2 Beyond the Farm Gate: Processing and Retail Consolidation Squeeze Dairy Farms & Consumers............................................3 The Many Faces of Dean..............................................................................................................................................................3 The Cost of a Carton: Consumers Pay Plenty, Farmers Get Little..................................................................................................3

Blocking Out the Competition........................................................................................................................................4



Organic Milk: A Not-So-Safe Haven for Dairy Producers............................................................................................5

Consumers Lose Out: Paying More and Getting Less..................................................................................................................6

Going the Distance.........................................................................................................................................................6



Pumping Up Production.................................................................................................................................................6

Taking Back Our Dairy Supply....................................................................................................................................................7 Endnotes..........................................................................................................................................................8

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ou’re not getting what you pay for in the dairy aisle these days. While shoppers are led to believe that the milk they purchase comes from tranquil pastures, where farmers watch over happy milk cows grazing on green fields, the reality is not so idyllic. There are some good options in the dairy case, but consumers need to know what to look for. Over the last 20 years, the dairy industry has been transformed at all levels, from the cows that produce its raw materials to the cooperatives that secure its prices and the processors that turn milk into finished products for consumers. Massive mega-dairies, whose herds may receive antibiotics and growth hormones to boost production, ship milk across the country to be mechanically separated and resold as everything from ice cream to industrial protein concentrates. Consumers no longer know where their milk comes from — or what is actually in many of the dairy products they consume.

Industrial Milk Production: A Beast of a System

Today’s dairy industry doesn’t work for consumers or for small- and mid-sized family farmers. These men and women — the ones who spend their time with herds and in pastures, who milk their cows twice daily, help them calve and ensure they receive proper veterinary care — receive subsistence-level prices or less for their milk and their labor. At the same time, consumers are paying higher prices at the grocery store. It seems like everyone is losing, except for the corporate middlemen and speculators who skim off all the cream.

Milk production has remained constant, however, because more and more cows are pushed onto the farms that remain. As late as 1998, the majority of milk produced in the United States came from small farms housing fewer than 200 cows. Only 10 years later, that breakdown has flipped, and the majority of U.S. milk is produced on large dairies with more than 500 animals each. In fact, more than a quarter of all milk now comes from industrial dairies with more than 2,000 cows, nearly 20 times larger than the national average herd size.2

In recent years, our country’s small- and mid-sized dairy farms have been disappearing, squeezed out by the consolidation of industrial mega-dairies that now dominate milk production. The United States is hemorrhaging dairy farms and farmers: Between 1997 and 2007, an average of 5,000 dairy farms were lost annually, for a total loss of more than 52,000 dairies in just a decade.1

Dairy 101

These new mega-dairies, some of which house 10,000 cows or more, hardly resemble the placid family farms many consumers imagine or that dairy processors still show on their packaging. Cows are crowded into high-density feedlots with no access to grass and milked in round-theclock shifts. More than 40 percent of cows in industrial dairies are injected with an artificial growth hormone called recombinant bovine growth hormone (rBGH) to increase their milk yields.3 When their udders become infected and swollen from the unnatural rate of milk production, they are treated with the same antibiotics needed (and increasingly unable) to combat human illnesses. As farms have grown larger, they have also moved westward. The emergence of mega-dairies has contributed to the decline of local dairy farms in the Southeast, Northeast and parts of the prairie states.4 Today, California is the nation’s largest dairy producer, accounting for nearly a quarter of U.S. milk.5 The state also houses the world’s larg-

These days, more milk is trucked halfway across the country because the local dairy farmer and milk bottler are out of business. All of this change was done in the name of efficiency — and may have made sense when gasoline was $2.50 a gallon. But if you have bought milk any time in the last year, you know that consumers aren’t benefiting from the new dairy landscape. – Andrew Martin, The New York Times, May 18, 2008 2

est dairy processing plant, which turns out more than one million pounds of cheese per day.6

Free Market or a Free Ride? Is all this consolidation just the result of natural market forces? Not necessarily. While it’s true that a larger share of big dairies than small turn a profit, there are many costs associated with dairy production that big operations don’t pay. If they did, their profit margins could be much smaller. Small dairies generate less manure and usually apply that manure to cropland as a fertilizer. In contrast, big dairies generate far more manure than they can use as fertilizer, so they must store it in giant lagoons — or apply it to cropland at excessive rates, where it leaches into groundwater and runs off into nearby rivers and streams. Residents are sickened by contaminated water or by the toxic gases that blow off the manure lagoons. But the cost of clean-up and medical care is covered by tax dollars or by the residents themselves, not by the dairies that cause the problem. Large dairies have also received a major discount on their feed bills thanks to federal policies that have kept the price of feed grains, such as corn, extremely low. Until 2007, dairies could actually buy feed on the market at a price lower than what the grain cost to produce. Small dairies are much more likely to produce their own feed, while large dairies — which have no cropland to speak of — buy feed almost exclusively.7 Research shows that industrial dairies saved a total of $6.5 billion between 1997 and 2005 because they were able to buy feed at below the cost of production.8

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Cheap water provides yet another subsidy to big dairies. Ironically, states like California, Texas and New Mexico — where water is hardly an abundant resource — have become major milk producers. These three states together house over 2.5 million cows, and since dairies can use over 150 gallons of water per cow each day in their production,9 water resources are being strained.10 California uses water from the Central Valley, where a state of emergency was declared in 2008 due to severe drought. In New Mexico and the Texas panhandle, the stressed Ogallala Aquifer is the main source of water for dairy feedlots. Most large dairies in these areas use water to flush manure out of the barns and into a lagoon for storage11 — a far more water-intensive method of manure management than small dairies, which collect manure solids to spread on cropland. A typical 1,000-head dairy in California generates between 50,000 and 75,000 gallons of liquid manure each day.12

Beyond the Farm Gate: Processing and Retail Consolidation Squeeze Dairy Farms & Consumers Not so long ago, most milk was sold by dairy farms to local milk processors that supplied the dairy case at local grocery stores. Today, a tiny handful of companies buy the majority of milk from farms and process it into dairy products and industrial food ingredients. The unique qualities of milk and milking make dairy farmers especially dependent on their buyers. Dairy farmers have to move their milk while it is still fresh, and that means they must sell to whichever buyer or buyers exist near them because more milk is produced every day. As the milk-processing industry has consolidated and specialized, farmers have fewer and fewer options in their area. The structure of the dairy market now looks like a giant hourglass: Milk produced on the 70,000 remaining U.S. dairy farms is funneled through a handful of powerful buyers and retailers — who exert tremendous pressure on farmers to sell their milk cheap — and then sold to millions of consumers. Dairy Farmers of America (DFA), a marketing “cooperative” with ties to big processing companies, collects and markets over a third of all U.S. milk.13 DFA is the primary — and in some regions, the exclusive — supplier to Dean Foods,14 which controls around 40 percent of the nation’s fluid milk supply,15 60 percent of all organic milk16 and 90 percent of soymilk.17 That means that a dairy farmer who wants to access that market will most likely have to go through DFA — and take whatever price he or she is offered.18

The Many Faces of Dean You may not see the name Dean in your dairy case, but that doesn’t mean it’s not there. Dean or one of its subsidiaries also owns or sells the following brands: AltaDena Berkeley Farms Borden Country Fresh Garelick Hershey’s (fluid chocolate milk only) Land O’Lakes (licensing agreement for the brand) Lehigh Valley Mayfield Farms Shenandoah’s Pride Verifine Horizon Organic Organic Cow of Vermont Silk Soymilk …and several dozen others.19 Consumers see a familiar label they may associate with a local or regional company, but the company behind all the labels is Dean.

The Cost of a Carton: Consumers Pay Plenty, Farmers Get Little The price of milk at the grocery store rose 40 percent between 1998 and 2007.20 Yet for every dollar that consumers spend on milk, dairy farmers receive only $0.27, 25 percent less than they received in 1998.21 The remaining share of that high price consumers pay is captured by dairy and food processing firms. For the past decade, the price that dairy farmers receive for their milk has been near or even below the cost of producing the milk, while the cost of fuel, labor and veterinary services has continued to rise. Even in 2007, with retail dairy prices at record highs,22 some dairy farmers in Pennsylvania were paid $0.15/lb. for milk that cost them $0.20/lb. to produce. But dairy production — like the production of many farm products — is slower to respond to these price signals than other markets. Dairy farmers have invested in barns, expensive milking equipment and herds that must be milked twice daily. During periods of low

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Dairy 101

prices, they cannot simply “turn off the cow” until prices rise again. That leads them to continue to produce even more when prices are low, sending prices further south with the increased supply. Recognizing that this pattern in the market could mean the death of the U.S. dairy industry, Congress stepped in during the 1930s to help balance supply and demand and keep prices stable. It did so by setting a minimum price that farmers must receive for their milk, which is determined using a complex series of formulas. The policy was supposed to provide fair income to dairy producers, much like a minimum wage.23 But beginning in 1981, this approach was abandoned. Congress lowered milk minimum price levels, keeping formulas in place but bringing an end to the “minimum wage” concept of pricing. The price farmers receive for their milk has declined steadily in real terms since that point, as the treadmill of overproduction and lower prices speeds ever faster.24

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Blocking out the competition Even worse, the pricing formulas are now vulnerable to manipulation by large dairy companies like Kraft.25 Here’s why: The price of cheddar cheese blocks traded on the Chicago Mercantile Exchange (CME) is the basis for the government’s milk price formulas. Because the trades take place between a very small number of huge dairy companies, Kraft and others can actually influence the price of cheese at the CME — and thus the price paid to farmers for their milk — by holding or selling cheese at strategic moments. The federal Government Accountability Office (GAO) recently concluded an investigation of cheese trades at the CME and found that they were prone to manipulation.26 There are alternative models out there. Some farmerowned companies try to offer their members a higher price than the going market rate and compensate by reducing overhead costs and/or raising retail prices. But given the consolidation that’s taking place even in alternative dairy markets, all farmers are feeling vulnerable. They’re also all seeing skyrocketing prices for their inputs. Due to bad weather, the hay needed to feed cows in the winter is scarce and expensive, and rising fuel costs are tightening the squeeze even more.

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Organic Milk: A Not-So-Safe Haven for Dairy Producers Over the years, the organic movement in the United States has built support for food produced in ways that ensured the health of the land, the animals, the farm family and the consumers drinking the milk. For several years, the popularity of milk certified as meeting U.S. Department of Agriculture (USDA) organic standards grew rapidly and organic producers were receiving great prices. But increasingly, not even the organic label is a safe haven from the price pressures that conventional dairy farmers experience. Organic’s small presence in the market once protected it from the cutthroat consolidation found elsewhere in the industry. That’s changed: With consumer demand for organic products growing by leaps and bounds, big business now has its eye trained on the sector. Dean’s acquisition of Horizon, AltaDena and Organic Cow of Vermont,27 the licensing of Stonyfield Farm’s fluid milk brand to H.P. Hood28 and the growth of organic store brands in large grocery chains like Safeway, Wal-Mart, Target and Trader Joe’s — all of which are supplied by Aurora Organic Dairy29 — have limited marketing options for organic producers.30

Indexed change in number of dairies (2000=100)

Intent on increasing production to meet the demand for organic milk, some of the large brands have cut a major corner by limiting or eliminating the amount of time their herds spend outside on grass (or in USDA-speak, the cows’ “access to pasture”). Both Horizon Organic and Aurora have been sued over their failure to comply with the standards at their large industrial-style dairy farms.31 While these companies clearly need to stop abusing a loophole in the organic standards, the real root of the problem is the USDA.

150

Change in Total Dairy Operations and Large Dairies in the United States, 1997-2007 Total dairy operations 500+ head operations

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– Steve Pechacek, president of the Midwest Organic Dairy Producers Association (MODPA)34

Although the department found Aurora responsible for 14 separate violations of federal standards for organic dairy production,32 USDA chose not to de-certify or even fine the dairy. Instead, it entered into a consent agreement with Aurora, which promised to make changes to its practices.33 When large organic dairies exploit lax USDA enforcement, the integrity of the organic label is weakened and smaller organic dairies and consumers lose out. Organic growers are now seeing record-high prices for feed, fuel and land. Just like conventional dairy producers, the price they receive for their milk doesn’t always cover their costs. With all the time and money they’ve invested in their operations, though, they have little choice but to take a pay cut to balance the books and hope to ride out the low prices. If things don’t turn around for them soon, some may be forced to close down.

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Allowing… a handful of factory farms to breach the standards in order to bring more organic milk to market… is unfair both to consumers and to all the farmers who uphold the standards to the highest level.

1997

1999

2001

2003

2005

2007

Source: USDA/NASS Agricultural Statistics Database

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Dairy 101

Consumers Lose Out: Paying More and Getting Less Going the distance The higher prices we’re seeing in the grocery store have nothing to do with product quality. They have a lot to do with the domination of the dairy market by a few giant global companies. Helped along by cheap oil, and driven by a desire to find the cheapest milk supplies possible, companies like Kraft and Nestlé have built supply chains that stretch across the country and across the world.35 These supply chains have replaced many of the local and regional ones that used to exist in the United States. Now that gas prices are skyrocketing, transporting milk long distances is becoming untenable—but until local and regional infrastructure is rebuilt, the cost of trucking dairy products from California to consumers as far away as the east coast will be added directly on to your grocery bill. To cut costs further, dairy processing companies like Kraft have begun to import something called Milk Protein Concentrate (MPC), a dried dairy byproduct produced in India, China, New Zealand and other countries.36 MPCs don’t have to come from cows’ milk; in fact, they often come from water buffalo, yak and sheep. Although the Food and Drug Administration (FDA) has never approved MPCs as a food ingredient,37 U.S. companies have been integrating them into food products anyway, using them in place of pow-

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dered milk sourced from U.S. producers. Next time you’re at the grocery store, check the ingredient list on a package of Kraft Singles for some evidence.38 The FDA’s blind eye to MPCs in our food has exposed consumers to a product that the agency has not determined is safe to eat, undercutting U.S. dairy producers in the process.

Pumping up production The “get big or get out” mentality has also driven the use of rBGH, an artificial growth hormone, in milk production. RBGH isn’t good for cows or humans. Cows injected with the hormone have higher rates of mastitis, an udder infection that must be treated with antibiotics.40 In turn, use of antibiotics in industrial dairies contributes to the growth of antibiotic-resistant bacteria, putting humans at risk.41 The Infectious Disease Society of America recently declared an epidemic of antibiotic-resistant infections.42 When rBGH is injected into cows, it increases their production of another growth hormone called IGF-1. IGF-1 is resistant to pasteurization; the European Commission found that consumption of milk from rBGH-treated cows increases daily intake of IGF-1 by humans.43 IGF-1 has been linked to breast and prostate cancer.44 While less than 10 percent of small dairies use rBGH, 42 percent of industrial dairies do.45

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Taking Back Our Dairy Supply The industrial dairy industry doesn’t serve consumers or dairy producers. To fix this mess, we need a comprehensive overhaul: New rules to level the playing field for family dairies, protect consumers and reestablish regional milk systems.

Recommendations: 1. End anti-competitive behavior in the dairy market, including price manipulation at the Chicago Mercantile Exchange and the control of dairy marketing, processing and distribution networks by a few companies. The Senate Judiciary Committee must hold hearings examining the scope of DFA’s stranglehold on the dairy industry, and Congress should support the efforts of the Commodity Futures Trading Commission to investigate price-fixing by DFA.46 Congress should also instruct the Department of Justice to follow through on its two-year investigation of anti-trust violations by DFA and Dean; the investigation was completed, but findings have been withheld from the public and no charges have been brought.47 2. Don’t leave dairy farmers out in the cold: Provide them with a fair wage. When milk prices are low, companies like Kraft and Dean save money on their major input. For dairy farmers, though, low prices can mean the end of the family business. Tell Congress to develop a new milk pricing formula that is based on the cost of production plus a fair return for family dairy farmers. There is a role for government in the dairy market, but it shouldn’t be to subsidize large dairy processors at the expense of farm families. 3. Hold industrial dairies accountable. Congress and government agencies must establish strong pollution laws, water-use permits and pollution reporting requirements for factory dairies and other large livestock operations. They should be regulated as industrial polluters, not family-scale farms. Federal and state governments should stop exempting large livestock operations from existing or proposed environmental laws. 4. Reestablish healthy local dairy production systems. The government has a responsibility to provide and protect a safe, healthy and affordable U.S. food supply. Instead of tacitly endorsing an influx of cheap foreign dairy imports, federal and state governments should help rebuild local and regional dairy production systems. Ask Congress to increase funding for regional value chains and food system infrastructure such as small-scale processing facilities.

Consumers need to understand what it means to them as they lose their good, dedicated U.S. farmers as corporations substitute our quality milk with adulterated dairy byproducts, such as milk protein concentrates and ultrafiltered milk, which are often imported from abroad. How many more tainted food products from China will it take before we realize our nation’s food supply is threatened if we don’t preserve our dedicated farmers who provide us with a local, fresh quality product? –LoriJayne Grahn, Minnesota dairy farmer and member of the National Family Farm Coalition39

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5. Protect consumers’ right to an artificial hormone-free dairy supply. Pressured by Monsanto, the manufacturer of rBGH, state legislatures and agriculture departments across the country have considered bills to prohibit farmers from advertising their milk as rBGH-free — and some have already passed such laws or regulations. That’s a violation of consumers’ right to know. You can fight back by buying rBGH-free milk, asking your grocer and school cafeteria to stock it, and contacting your legislators if a bill has come up in your state. Stay tuned to the Food & Water Watch website for updates on this issue. 6. Protect the integrity of organic milk standards. The USDA has turned a blind eye to violations of the organic standards by big dairy companies. Consumers should demand that USDA finish up revisions to the organic standards that close the loophole about access to pasture and strongly enforce the organic standards for dairy. Stay tuned to the Food & Water Watch website for updates on this issue. 7. Protect the integrity of milk. Demand that FDA stop companies from adding MPCs to their products and that the agency not change the definition of milk, yogurt or ice cream to allow for the inclusion of MPCs. Consumers should check the label of all dairy products and refuse to buy products with MPCs added.

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Endnotes: 1 USDA/NASS (2008). Agricultural Statistics Database. Accessed August 5, 2008. Available at www.nass.usda.gov/QuickStats/. 2 Ibid. 3 “USDA/Animal and Plant Health Inspection Service (APHIS) (2007). Part I: Reference of Dairy Cattle Health and Management Practices in the United States,” p. 79. 4 USDA/NASS (2008). Agricultural Statistics Database. Accessed August 14, 2008. Available at www.nass.usda.gov/QuickStats/. 5 USDA/NASS (2008). Agricultural Statistics Database. Accessed August 13, 2008. Available at www.nass.usda.gov/QuickStats/. 6 Bowman, C. (2005). “Cheese Maker, State Settle.” Sacramento Bee, October 26, p. A1. 7 Short, Sara (2004). Characteristics and Production Costs of U.S. Dairy Operations. Statistical Bulletin No. 974-6. USDA/ERS. 8 Starmer, E., and T.A. Wise (2007). “Feeding at the Trough: Industrial Livestock Firms Saved $35 Billion from Low Feed Prices.” GDAE Policy Brief No. 07-03, December. Medford, MA: Global Development and Environment Institute of Tufts University. 9 Weida, W. J. (2000). “A Citizen’s Guide to the Regional Economic and Environmental Effects of Large Concentrated Dairy Operations.” Department of Economics, Colorado College, and the Global Resource Center for the Environment (GRACE), New York, NY. 10 USDA National Agricultural Statistics Service (2008). Quick Stats database. Accessed August 6, 2008. Available at www.nass. usda.gov/Data_and_Statistics/Quick_Stats/index.asp#top 11 Meyer, D.M., I. Garnett, and J.C. Guthrie (1997). A Survey of Dairy Manure Management Practices in California. J Dairy Sci 80:1841-1845. 12 Harter, T., M. C. Mathews, and R.D. Meyer (2001). Effects of Dairy Manure Nutrient Management on Shallow Groundwater Nitrate: A Case Study. Presentation at the ASAE Annual International Meeting, Sacramento, CA, July 30-August 1. 13 Hendrickson, M., W.D. Heffernan, et al. (2001). Consolidation in Food Retailing and Dairy: Implications for Farmers and Consumers in a Global Food System. Columbia, MO: National Farmers Union. 14 Dean Foods Co. (2002). 10-Q SEC Filing, Item 2. Accessed September 1, 2008. Available at http://sec.edgar-online.com/20 02/08/14/0000950134-02-010148/Section7.asp. See also Dairy Field Magazine (2003). D-Brief, Issue 1. Accessed September 2, 2008. Available at www.idfa.org/dbrief/dbrief010903.html. 15 Cheng, A. (2007). “Dean Foods Cuts 2007 Forecast on Milk Price.” MarketWatch, June 12. Available at www.marketwatch.com/news/story/dean-foods-cuts-profit-forecast/story. aspx?guid={8898B56A-DC16-4A3E-930F-13E2F5C979B1} 16 Scott, C. (2006). “Organic Milk Goes Corporate.” Mother Jones, April 26. Available at www.motherjones.com/news/update/2006/04/organic_milk.html

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Silverstein, B. (2007). “Silk Soymilk: Smoooth.” Brandchannel. com, Brand Features: Profile. December 31. Accessed August 19, 2008. Accessible at www.brandcameo.net/features_profile. asp?pr_id=367. 18 Martin, A. (2008). “Yes, it’s a Cooperative. But for Whom?” The New York Times, May 18. 19 Dean Foods Co. (2002). 10-Q SEC Filing, Item 2. Accessed September 1, 2008. Available at sec.edgar-online.com/2002/0 8/14/0000950134-02-010148/Section7.asp. See also Oligopoly Watch (2003). Oligopoly Brief: Dean Foods. Accessed August 15, 2008. Available at www.oligopolywatch.com/2003/10/08.html. 20 Bureau of Labor Statistics (2008). Consumer Price Index, Milk. Accessed August 7, 2008. Available at www.bls.gov/cpi/#data. 21 USDA/ERS (2008). Price Spreads from Farm to Consumer: At-Home Foods by Price Group (Dairy). Accessed August 7, 2008. Available at www.ers.usda.gov/Data/FarmToConsumer/pricespreads.htm. 22 Bureau of Labor Statistics (2008), op. cit. 23 Blayney, D.P. and M.A. Normile (2004). Economic Effects of U.S. Dairy Policy and Alternative Approaches to Milk Pricing. U.S. Department of Agriculture, Report to Congress, July. 24 USDA/ERS (1982-2003). Dairy Yearbook. 17

25 Grant, J. (2006) “CME in Cheese Price Fix Investigation.” Financial Times, August 17. Available at http://us.ft.com/ftgateway/superpage.ft?news_id=fto081720061727374434. See also: Mueller, W.F., B. W. Marion, M. H. Sial, and F.E. Geithman (1996). Cheese Pricing: A Study of the National Cheese Exchange. Prepared for the Wisconsin Department of Agriculture, Trade, and Consumer Protection. Food System Research Group, Department of Agricultural Economics, University of Wisconsin-Madison. 26 US GAO (2007). Spot Cheese Market: Market Oversight has Increased, but Concerns Remain about Potential Manipulation. Washington, DC: U.S. Government Accountability Office 27 Burros, M. (2006). “Survey Ranks ‘Organic-ness’ at Dairies.” The New York Times, March 22. Available at www.nytimes. com/2006/03/22/dining/22milk.html. 28 Phillips, D. (2005). Hood’s Dairy Nation. Dairy Foods, January 10. Available at www.dairyfoods.com/CDA/Archives/6a0047062e 0a7010VgnVCM100000f932a8c0____. 29 Cornucopia Institute (2007). Enforcement Hammer Falls on Nation’s Largest Organic Factory Dairy. Press release, August 31. 30 Hendrickson, M., W.D. Heffernan, P. Howard and J. Heffernan (2001). Consolidation in Food Retailing and Dairy: Implications for Farmers and Consumers in a Global Food System. National Farmers Union.

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Dairy 101 Cornucopia Institute (2008). America’s Largest Corporate Dairy Processor Muscles Its Way into Organics. See also Cornucopia Institute (2007). Lawsuit Announced Against Nation’s Biggest Organic Dairy. 32 Bradley, M. (2007). Notice of Proposed Revocation. Letter to Marc Peperzak, CEO, Aurora Organic Dairy, April 16. 33 USDA (2007). Aurora Organic Dairy Signs Consent Agreement with USDA’s Agricultural Marketing Service. News Release no. 0228.07. 34 NODPA (2006). Family Farmers Say No to Factory Farms in Organic Dairy. Press release, April 14. 35 Ruff, J., Kraft Foods (2004). Re: Prior Notice of Imported Food. Letter to the FDA, July 8. See also FoodProcessing.com (2008). “Ingredients from Where?” Accessed September 3, 2008. Available at www.foodprocessing.com/articles/2008/037. html?page=print. 36 Krebs, A. (2001). “Kraft ‘Cheese’: Adulterated Food?” The Agribusiness Examiner, No. i115, May 7. 37 Bunting, J. (2005). Testimony Regarding Proposals Seeking to Amend the Class I Fluid Milk Product Definition. Federal Register, Vol. 70 No. 69, p. 19012-19015. 38 Blayney, D., M. Gehlhar, C. H. Bolling, K. Jones, S. Langley, M. Normile, and A. Somwaru (2006). U.S. Dairy at a Global Crossroads. Economic Research Report No. 28. Washington, DC: USDA/Economic Research Service, p. 8. 39 National Family Farm Coalition (2008). U.S. Dairy Farmers Host Teleconference Outlining Crisis in Dairy Industry. Press Release, March 3. 31

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Doohoo I. et al. (1998). “Report of the Canadian Veterinary Medical Association Expert Panel on rBST”. Health Canada, November. 41 Pew Commission on Industrial Farm Animal Production (2008). Putting Meat on the Table. Washington, DC: Pew Commission. 42 Spellberg B, Guidos R, Gilbert D, Bradley J, Boucher HW, Scheld WM, Bartlett JG, Edwards Jr. J, America IDSo (2008). The Epidemic of Antibiotic-Resistant Infections: A Call to Action for the Medical Community from the Infectious Disease Society of America. Clin Infect Dis 46.Curr Opin Microbiol 4: 493-9. 43 European Commission (1999). “Report on Public Health Aspects of the Use of Bovine Somatotrophin.” In Food Safety — From Farm to Fork. 44 Yu, H., and T. Rohan (2000). Review: Role of the Insulin-like Growth Factor Family in Cancer Development and Progression. Journal of the National Cancer Institute 92:1472-89. 45 USDA/APHIS (2007), op. cit. 46 American Agriculture Movement, American Corn Growers Association, et al. (2008). Letter to Senator Patrick Leahy, Chair, Senate Judiciary Committee. June 26. 47 Ibid. See also NFFC (2008). Family Farm and Consumer Groups Urge Senate Judiciary to Investigate Dairy Farmers of America (DFA). Press Release, July 6. 40

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